Enel Brasil considers transparency and integrity essential to its business and, as such, follows the Ethical Standards of Enel S.p.A., applied to all companies within the group worldwide, all its employees, and the supply chain. These standards express the ethical commitments and responsibilities in the performance of business activities and operations carried out by employees.
The ethical behavior of the Enel group is also based on the Zero Tolerance Plan for Corruption and the "Guidelines 231." Additionally, Enel Brasil follows the Brazilian Law No. 12,846/2013 (Anti-Corruption Law).
Ethical Standards: covers the principles of the Universal Declaration of Human Rights, the Global Compact, and the Declarations of Principles of the International Labour Organization (ILO), as well as the Millennium Development Goals.
Zero Tolerance Plan for Corruption: reflects a commitment to combat corruption, following the principles of the Global Compact and criteria recommended by the non-governmental organization Transparency International.
Italian Decree 231/01: defines the Guidelines 231 and establishes a Compliance Program identifying the expected behaviors of related parties of Enel's non-Italian subsidiaries.
The company also has a Program for Preventing Criminal Risks (Integrity Program), which describes the expected behaviors and general principles of action for Enel Group employees in Brazil. These behaviors embody fundamental values of the company to achieve its business objectives while preventing risks. The program applies to all employees in their roles of representing, managing, operating, or controlling the company, as well as those who act on behalf of the company. Additionally, the company requires all affiliates, associates, suppliers, and partners to adopt a behavior that is consistent with the established ethical principles.
To ensure the dissemination of Enel Brasil's ethical commitments to new employees, the company conducts the "Welcome" program - highlighting anti-corruption initiatives. Furthermore, during the selection process for new employees, the candidates sign a conflict of interest declaration. If a candidate indicates the existence of any conflict, an analysis of its criticality is conducted, and if necessary, a formal consultation with Internal Audit is carried out. In cases of corruption, employees are terminated.
In its relationship with suppliers, Enel Brasil also takes measures to prevent conflicts of interest, and in cases of corruption, suppliers have their contracts terminated, subject to legal actions.
To ensure the control of actions identified as unethical, Enel Brasil has various tools of correct handling and assessment of these issues.
Ethical Channel – Available on the intranet and the internet, the Channel receives reports of inappropriate corporate practices and behaviors related to confidentiality, conflicts of interest in audits, misappropriation, environmental issues, health and safety, and problems with suppliers and service providers.
Internal Audit – Administratively linked to Enel Brasil's holding company, with functional dependence on Enel S.p.A. in Italy, the Internal Audit department assesses compliance with norms and procedures and has an annual audit program coordinated at the corporate level to ensure its autonomy from the company's directorates. The audits cover all areas of the company and consider aspects such as fraud and corruption.
Internal Control Unit – Established to assist in evaluating, validating, and certifying internal controls that generate financial information for Enel Brasil's companies. The unit was created to meet the requirements of Section 404 of the Sarbanes-Oxley Act of Italian Law 262/05. The team comprises an internal committee consisting of assessors (supervisors and technical analysts), legitimators (managers), and certifiers (directors), and it uses the GRC-PC (Governance Risk Compliance – Process Control) system for internal control management.
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